Privacy Policy

Privacy Policy

Privacy Policy




We respect the privacy of persons using Bank Hapoalim Ltd. services (“We” or “The Bank”)

The privacy policy below applies to every service offered by the Bank, as well as to the Bank’s websites and applications, to use of digital information and communication channels as well as others, such as email, messages and chats, telephone calls with the bank and any other service provided by the Bank.

The services listed above will hereinafter be known, jointly and separately as “The Services”.

The policy specifies the information compiled by the Bank, including personal information as defined in the Protection of Privacy Law -1981 (Hereinafter: “Information”) and the use made by the Bank thereof. The policy also includes information about the use of technological tools and other aspects related to the compilation, use and transfer of information as part of the services.

The various services, including those that require your registration or identification, may be subject, according to their conditions, to additional specific provisions and conditions regarding privacy and use of information. In these cases, this privacy policy will also apply to the terms of use and to specific privacy policies of said services. Where there is a discrepancy between the provisions of the privacy policy and the terms of use, privacy or agreement of specific services, the terms of use and provisions of privacy of the specific services will supersede.

The privacy policy is worded in masculine form only for the sake of convenience.

1.       Consent to disclose information and the repercussions of failure to consent

1.1.Unless otherwise specified and particularly with regard to the service in question, you will not be subject to a legal requirement to disclose information to be requested of you and its delivery depends on your wishes and consent. Concurrently, without obtaining the information or full details being requested, which are required for the purposes specified in this policy, the Bank may not be able to provide you with all or some of the services.

Some details may be required of you to disclose, or for the bank to receive, in accordance with the provisions of the Law or the directives of the Bank of Israel.

1.2.Use of our services constitutes your consent to the compilation, use, disclosure, transfer and retention of your information that we will obtain in accordance with this privacy policy.

2.       How we compile information

We compile and process information about you and about your related parties that will be received in any of the following ways:

2.1.Information that will be disclosed to us directly as part of the account opening process and management, as well as information that is to be provided by you and/or by any party acting on your behalf, directly or indirectly, as part of a request or receipt of other services from the Bank.

2.2.Information to be compiled by the Bank from third parties, including authorities, authorized entities, external suppliers, external databases, whether originating in Israel or outside of Israel, including information sent from the European Economic Community, visible sources, such as information from the internet, social media and other public information (jointly: “Third Parties”).

You confirm that, to the extent that information is disclosed by you in relation to another subject of information, you obtained prior consent of that subject of information to the disclosure of the relevant information to the Bank for the purposes set forth in this privacy policy.

 

3.       The information we compile

Said information may include the following types of information, and may combine and cross-reference types of information:

3.1.Identification and contact details - Identification and contact details including full name, ID Number, contact information, particularly mobile phone and email address, full address, information for the purpose of identification such as face image, other relevant information as needed.

3.2.Information required under the law - With regards to the requested service, the background to the request, the Parties that will operate as part of the service, the nature of the activity, etc. for the purpose of anti-money laundering and financing of terrorism, compliance and risk management.

3.3.Financial and economic information – Financial and economic information, including information about salaries, income, liabilities, assets, accounts, and other information required by the Bank as part of its ongoing work.

3.4.Information about use of the Bank’s services – Information pertaining to the account and other transactions performed as part of the services.

3.5.Documentation of communication and images – Written, vocal or visual information that is sent through the various communication and information channels, including content included in email correspondences, phone calls or video calls, chats, electronic messages and other messages that are sent between you and the Bank, as well as documentation from security cameras positioned at Bank sites and branches.

3.6.Any other information required as part of the Bank’s ongoing work and/or for the purposes specified in this policy.

 

4.       The purposes for which we compile information

Information provided to us or that we will compile, including information received by the bank from third parties, will be used by the Bank, as needed, for the following purposes:

4.1.Opening an account and receiving Bank services;

4.2.The Bank’s ongoing work;

4.3.Review of applications to receive services and decision making pertaining to the services, their scope and the manner in which they are given;

4.4.Risk management and credit risk, including analysis and rating of credit risk, as well as management of other risks, such as identifying and preventing fraud or preventing misuse of the services, information security, monitoring activity in accordance with the law including foreign law.

4.5.Improvement of services for Bank customers including the development of new products and services. This will help you conveniently benefit in a user-friendly manner from Bank services, which are offered through digital means in particular, based on your selected preferences;

4.6.Analysis of the information, segmentation, characterization of usage of services habits as well as consumption habits, direct mail and advertising information focus.

4.7.Marketing and advertisement through various means in accordance with the law;

4.8.To protect the legitimate interests of the Bank, including as part of the defense in legal proceedings and prevention of actions that violate the terms of use of the Services, the privacy policy and law;

4.9.To uphold a legal requirement or provision of the law inside or outside of Israel to which the Bank is subject.

 

5.       Processing through automated and other means

5.1.Information may be processed in automated, computer, digital or other means.

5.2.Use will be made, on a need basis, of models and algorithms that are based on machine learning and in artificial intelligence (AI) systems, for analyzing information, for autonomous or automatic decision-making and on the creation of new content including content in human language (GENERATIVE AI). These systems will hereinafter jointly be known as “Artificial Intelligence”.

5.3.The Bank may process transform information that is personally identified with you to unidentified information (in a reasonable manner).

 

6.       Transfer and/or sharing of information

The Bank may regularly or periodically transfer information compiled about you, as specified above, to third parties, including transfer of information outside of the borders of Israel, to implement the objectives for which the information was compiled as specified above.

The Bank may transfer information under the following circumstances and to the following parties inside or outside of Israel:

6.1.As part of the activity of third parties in order to complete a requested transaction or when it is necessary for the operation of services and management of your account; within this framework, the Bank may be required to disclose information to any other party, as well, involved in payment services, including other banks, credit card companies and issuers of other payment methods, clearing houses, consolidators and payment service suppliers, as well as beneficiaries of payments.

6.2.As part of the Bank's outsourcing of activities to third parties and receiving services from various suppliers, including, but not limited to, subcontractors, communications computing and operations services, cloud computing and data processing services, and artificial intelligence service providers. Service providers will be entitled to retain, store and use the information to provide their services.

6.3.As part of its activity with business-related companies, for the declared purposes of use and permitted under any law, to provide services, including risk management in the Bank’s group.

6.4.If required to do so under the law, including foreign law, the directives of the Bank of Israel, court order or directive by a relevant authority.

6.5.To clearance systems of payment methods, financial assets and information.

6.6.To counterparties of transactions or deals, whether they are an intermediate party or final party.

6.7.To a new or other corporation, if the Bank or any other company from the Bank’s group organizes its operations in another corporate framework, and if it merges with another entity or if it merges its operations with the operations of a third party.

6.8.To assignee entities – in the case of assignment or lien by the bank or for the purpose of implementing assignment or lien.

6.9.In addition, the Bank will provide, with regards to foreign securities, any information it or service provider to the bank must provide under a foreign law to the supervising authority or to another party under said foreign law.

6.10.      To other parties subject to your consent.

 

7.       Compilation, analysis and marketing technologies

We may use various technologies such as cookies and compilation, analysis and marketing tools as specified below.

7.1.In digital services that are offered by the Bank, use is made of cookies, pixels tags, etc. These technologies are sent to the device from which you are browsing and automatically store various information files on it about your use of the services, such as IP address, domain name, device location and characteristics, connection times and duration, etc. These technologies will hereinafter jointly be known as “cookies”.

The cookies used by the Bank are necessary for information security and the prevention of misuse while helping the Bank identify your device in order to learn about your use of the services, and to provide you with a convenient and user-friendly interface when using digital means, for the purposes of personalized online advertising and for the other purposes specified in this policy.

When using cookies, the Bank does not compile identifying information about you, such as name, telephone number, email address, etc.

7.2.The Bank uses third-party tools on the website to analyze the use of the Bank's websites, apps and other digital services, and for personalized advertising purposes.

Use is made of Facebook, Google Analytics, Google Firebase, Google Ads, Taboola, Outbrain, TikTok, LinkedIn, Appsflyer, Acoustic, and Google Tag Manager to analyze anonymous, statistical, and aggregated information about traffic and activity on the site, as well as ad personalization services through the Google Signals tool, for Google users whose accounts have the ad personalization option enabled, the privacy policy of which appears at the following link:https://support.google.com/analytics/answer/7532985?hl=iw

These tools are also used by the Bank for advertising and remarketing purposes - digitally and throughout the web, for example with the help of Google Ads, Google Signals, which may be tailored to your preferences based on the characteristics of your digital activity. The Bank also uses reporting on appearances on Google media and reporting on demographics and areas of interest in Analytics. Use is also made of Facebook Pixel - for personalized advertising on social networks.

7.3.In the operation of these tools, the companies that provide the tools (including Google, Taboola, Outbrain, LinkedIn, TikTok and Facebook) use their cookies to compile information such as your IP address, unique identifiers for the device from which you are browsing and its characteristics, your activity, the pages you viewed, etc. The cookies may allow them to identify your device even after you leave the Bank websites. The information compiled by them may be stored in the databases of companies outside of Israel.

If you would like to learn more about the use these companies make of their cookies and the information compiled through them, you can do so on their official websites.

For your convenience, the following links are attached:

https://www.facebook.com/policies/cookies

https://policies.google.com/technologies?hl=en

https://acoustic.com/cookie-policy

https://www.appsflyer.com/legal/services-privacy-policy

https://www.taboola.com/policies/cookie-policy

https://www.outbrain.com/privacy/cookies

https://www.linkedin.com/legal/cookie-policy

https://www.tiktok.com/legal/page/global/cookie-policy/en

 

In these links you can also find information about the options they offer you to manage the use of their cookies, including choosing not to use these tools during your browsing (opt out), for example through the following digital means:

http://www.aboutads.info/choices

http://www.youronlinechoices.eu

You can also use Google Analytics opt-out add-on, which is designed to be installed on web browsers.

You can change your privacy preferences or access to information. You can block or restrict cookies in the browser you use by changing the settings of the browser installed on your device. Blocking, as specified, can be complete or partial, depending on the type of browser.

Please note, blocking or restricting cookies may prevent you from accessing or using digital or various parts therein, or may affect your browsing experience.

The Bank offers options to restrict use of cookies to browsers of its website. Additionally, the direct digital banking services and the account management app provide an option to change these preferences in the user settings on the direct banking page and in the app settings, accordingly.

Google and Facebook offer in the links specified above the options to change cookies preferences in the tools operated by them.

Various websites and initiatives across the Internet also offer various information and tools for managing and controlling cookies, such as:

http://www.aboutads.info/choices

http://www.youronlinechoices.eu

You can also change all or some of the privacy settings, access permissions, and preferences regarding how information is shared in the settings menu of the device being used, as well as block the use of technological compilation tools and other permissions requested by online and digital services, subject to the terms of service in question, in the settings menu of the end equipment. Delivery of information can also be managed as well as its disclosure to third parties in accordance with its terms of use.

In this regard, when a location-based service is active on end equipment, the Bank may use this location. The location of the end equipment may come from GPS signals, Wi-Fi access points, as well as cellular antennas, whether the various bank applications are active or turned off.

When the notifications service is active on the end equipment, the Bank will be able to send various notifications related to activity in the Bank's apps and other updates, as well as to offer various products or services, based on the information analyses conducted by the Bank in accordance with the provisions of this policy, and in the additional terms of service, and in accordance with the law. The notification service can be managed by changing the settings on the end device.

Blocking or restricting access and sharing of information may prevent you from accessing or using the services or various parts thereof or may affect the usage and browsing experience.

 

8.       Your rights

8.1.Subject to the provisions of the law, you can review your information that is found on the Bank’s databases and even request the Bank to amend or delete this information if it is inaccurate, incomplete, unclear or outdated.

To exercise this right, send the bank a written request to the address listed below about this policy.

8.2.The Bank may refuse this request subject to the provisions of the law.

8.3.Additional information about the privacy protection laws in Israel and your rights with regards to your information can be found on the Privacy Protection Authority at the following address:

https://www.gov.il/he/Departments/the_privacy_protection_authority

 

9.       Information security

Information security is important to us. We comply with the standards adopted in the sector and adopt technological as well as organizational security measures

that are appropriate and advanced to protect information, including protection against unauthorized access, loss, destruction and integrity of information. Despite the specified, it is clarified that the Bank cannot guarantee absolute protection of information.

More on information security can be found in this link:

https://www.bankhapoalim.co.il/he/data-security-and-digital-scams

 

10.   Links to websites / external pages

In this policy and the various terms of use of the Bank’s various services there may appear links, or referrals to addresses or internet pages that are not those of the Bank. These may appear as clickable banners or as adds or in any other manner. These pages and sites are subject to separate terms of use and privacy policies of the sites or services being referred to in the link and the Bank has no control over them. The Bank’s privacy policy does not apply to these websites and/or webpages. Accordingly, you should confirm the terms of use and privacy policy of these websites, if you visit them before you use them.

 

11.   Change in the privacy policy

The Bank may change or update this privacy policy at its sole discretion and subject to the law from time to time as it appears on the website.

 

12.   Details of the owner of the database / controlling interest of the database and means of contact

The owner of the database / controlling interest of the database: Bank Hapoalim Ltd.

If you have any questions about our privacy policy or if you want to contact us, you can do so at 50 Rothschild Blvd. Tel-Aviv Yafo, Zip Code 6688314 Telephone: 03-5673697 (extension 3) or email: mailbox.privacy@poalim.co.il

 

13.   Additional details: information sent from the European Economic Area and provisions under foreign law

Regarding information sent to the Bank from the European Economic Area (EEA) and information pertaining to the disclosure of personal information and its use under foreign law, in addition to this policy, special notices published on the Bank’s website.

-      Information that was sent to Israel from the European Economic Area.

https://www.bankhapoalim.co.il/sites/default/files/media/PDFS/Additional-Disclosure-regarding-Personal-Data-Transferred-from-EAA.pdf

-      Residents of California

https://www.bankhapoalim.co.il/sites/default/files/media/PDFS/bhbm_ccpa_notice_at_collection2.pdf

-      Customers who are residents of California

https://www.bankhapoalim.co.il/sites/default/files/media/PDFS/bhbm_ccpa_privacy_policy.pdf

-      Residents of Switzerland 

https://www.bankhapoalim.co.il/sites/default/files/media/PDFS/fadp_notice_for_online_services.pdf